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This newsletter is brought to you courtesy of The Partners Group and member company, Kerr-Cruickshank, Inc. We are a multi-specialty insurance and consulting firm
that offers creative employee benefits solutions to our customers. As a valued client or associate, we feel this weekly update provides valuable information to you.
Dear Valued Client:
Our clients providing prescription drug coverage to employees and their dependents must notify Medicare Part D-eligible individuals whether their coverage qualifies as "creditable" – i.e., is actuarially equivalent to or better than
Medicare Part D coverage. In cases where the coverage is not creditable, notices must be provided indicating its non-creditable status. The notice must be provided to all Medicare Part D-eligible individuals who have prescription drug
coverage – including active employees, disabled employees, employees on COBRA and retirees, as well as Medicare beneficiaries who are covered as spouses or dependents (including those spouses or dependents who may be disabled or on COBRA).
Because an employer may not always know who these participants are in their health plan, it may be easier to simply distribute your notice to all of your health plan participants.
Notices of creditable or non-creditable coverage must be provided prior to the start of the annual Medicare Part D open enrollment period for the following calendar year. The CMS has indicated it is acceptable to include your annual notice
in your benefit plan open enrollment packets each year (with certain rules that ensure the notice is prominently identified). If you know your plan's creditability status for plan years ending in 2009 and you have not yet made your
Medicare Part D Creditable Coverage notice, please do so before November 15, 2008. If you do not yet know your plan's creditability status for plan years ending in 2009, please make notification of your plan's current creditability status
prior to November 15, 2008, and notify as soon as possible if you learn of a subsequent change in your plan's creditability status for 2009. The annual Medicare Part D enrollment period for 2009 will begin on November 15, 2008 and end on
December 31, 2008.
Word Document Template:
Med D Creditability Notice 2008.doc
Med D Non-Creditability Notice 2008.doc
Group health plan sponsors providing prescription drug benefits must also submit an annual disclosure form to CMS providing basic information about the plan and whether prescription drug coverage offered under the plan is creditable
coverage. For group health plans with plan years ending in 2009, the disclosure must be made within 60 days after the first day of the onset plan year. The plan sponsor must report the beginning date and ending date for the plan year on
each disclosure notice. In addition, a group health plan sponsor must file an amended disclosure form with CMS within 30 days after the termination of the plan or any change in the creditable coverage status of the prescription drug
coverage provided under the plan (such as the termination of any prescription drug option).
Note that The Partners Group will not be making this online disclosure on your behalf as CMS precludes us from doing so. Please give any member of your service team a call, however, if you would like for us to walk you through the online
disclosure to the CMS. The link to the online disclosure form is:
http://www.cms.hhs.gov/CreditableCoverage/
Currently, there are no other methods for providing the notice.
Please contact any member of your service team if you have any questions regarding your Medicare Part D notice requirements, or if we can help you in any way.
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